Germany tightens VAT refund rules
Germany tightens VAT refund rules
for non-EU businesses
From 1 January 2026, businesses outside the EU must upload invoices and import documents digitally to the BZSt portal when claiming a VAT refund in Germany. Paper submission is no longer the default.
New documentation rules from 1 January 2026
The German Federal Central Tax Office (BZSt) has updated the rules for VAT refund applications submitted by businesses established outside the EU. From 1 January 2026, any invoice or import document with a total value exceeding 250 EUR must be uploaded electronically to the BZSt Online Portal (BOP) as part of the application.
Previously, businesses could submit invoices by post or on a storage medium. Going forward, digital upload via BOP is the standard. Paper may still be permitted only in exceptional hardship cases, which must be requested and approved separately by the BZSt.
A second change also took effect in 2026: refund decisions are now made available electronically for data retrieval, rather than being posted. This applies to all correspondence relating to the VAT refund procedure unless a hardship exception applies.
Thresholds and deadlines at a glance
Note: fuel invoices are excluded from the VAT refund scheme regardless of amount. The BZSt can request original invoices even where the total is below 250 EUR.
Eligibility for non-EU businesses
To claim a German VAT refund, a non-EU business must generally satisfy a reciprocity requirement — meaning Germany reimburses VAT to businesses from your country because your country does likewise for German businesses. The list of qualifying countries is set out in the BMF letter of 9 November 2022.
Check reciprocity
Verify that your country of establishment is on the BZSt-approved reciprocity list. If not, participation in Non-Union OSS or IOSS may still open the door to a refund.
Register for BOP access
BOP registration can take several weeks due to postal delivery of access credentials to addresses outside Germany. Register early — well before the 6-month application deadline.
Submit the application with uploaded documents
Log in to the BOP, complete the refund form, and upload all invoices and import documents exceeding 250 EUR. Applications are capped at 1,000 line items.
Retrieve the decision electronically
From 2026, the BZSt issues decisions via the BOP inbox rather than by post. Check your BOP mailbox regularly after submission.
Northern Ireland note: Northern Irish businesses follow EU Member State rules for goods purchased in Germany, but third-country rules apply to services.
We handle VAT refunds across the EU
Tell us where you incurred VAT and we will advise whether a refund is available and manage the process end-to-end.
Common questions
Do I still need to send original invoices?
The BZSt may still request original invoices at any time, including for documents below 250 EUR. Upload all documents in full — partial submissions are not accepted.
My country is not on the reciprocity list — can I still apply?
Yes, if you participate in the Non-Union OSS or Import One Stop Shop (IOSS) scheme. Outside those schemes, the reciprocity requirement must be met.
Is interest paid if the refund is delayed?
Yes. If payment is made after a legally defined period, interest accrues at 0.15% per month from 15 months after the end of the relevant calendar year. Import VAT refunds are excluded from interest.
Let us manage your German VAT refund
Tell us where VAT was incurred, which countries are involved, and the refund period. We will handle BOP registration, documentation, and submission.
Also see: Germany VAT guide